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The new measures focus on the Russian military and defense industry and aim at further limiting Russia’s access to military technologies. The new measures include asset freezes on new individuals and entities, additional export restrictions on dual-use goods, advanced technologies and goods that could contribute to the enhancement of Russian industrial capacity, along with an addition to the list of partner countries for the import restrictions on iron and steel.
The new sanctions package entered into force on 23 February 2024 and 24 February 2024. The new measures are set out in the two regulations accessible here and here.
Below, we outline a selection of key changes to be noted by Danish companies to ensure continued compliance with EU sanctions against Russia.
New export restrictions have been enacted with a special focus on weakening Russia’s military and industrial capabilities and limiting Russia’s access to dual-use and advanced technology.
Regulation 2024/745[1] (amending Regulation 833/2014[2]) extends the list of items subject to export restrictions. The new measures expand export restrictions by listing a number of new goods in Annex VII (advanced technology) and Annex XXIII (items that could contribute to the enhancement of Russian industrial capacity). The new listing includes key drone components, such as aluminum capacitors with military applications, electrical transformers, static converters and inductors. For the new goods listed in Annex XXIII, the ban will not take effect until 25 May 2024 for the performance of contracts concluded before 24 February 2024.
Further, the list of entities subject to the enhanced restrictions in relation to dual-use and advanced technology items in Annex IV is extended to cover an additional 17 new Russian entities and 10 non-Russian entities. The newly added non-Russian entities are engaged in electronic component trading and some of these have been involved in the circumvention of trade restrictions through parallel imports of prohibited goods to Russia and similar measures. Among the non-Russian entities, four are registered in China and one of each registered in Kazakhstan, India, Serbia, Thailand, Sri Lanka and Turkey. The designations entail that EU national authorities shall (except in exceptional circumstances) not authorize the export of dual-use items and advanced technology items to the covered entities.
In addition to the export restrictions contained in the 13th sanctions package, earlier this month the EU updated its List of Common High Priority Items covering dual-use and advanced technology items that have been identified as critical to Russia’s ability to wage war. Sale and export of such items require special attention and due diligence from EU operators. The updated list is accessible here.
The new sanctions impose asset freezes on additional 106 individuals and 88 entities, covering primarily actors in the Russian military and defense sector, particularly those manufacturing drones, missiles and high-tech components. With the new listing, there are now more than 2,000 names on the list subject to the asset freeze measures. The updated asset freeze list is set out in Annex I in Regulation 2024/753[3] (amending Regulation 269/2014[4]).
The 13th sanctions package adds the United Kingdom to the list of partner countries that enforce restrictive measures on imports of iron and steel from Russia. These partner countries, which now include Norway, Switzerland and United Kingdom, also apply a set of import control measures that closely align with those of the EU.
The scope of applicable sanctions targeting Russia has again been extended and Danish companies should ensure that their sanctions compliance programmes, policies, screening processes and payment processes are updated to ensure that the newly enacted sanctions are appropriately addressed.
In light of the enhanced export controls and new additions to the asset freeze lists, we recommend that Danish companies conduct re-screening of products and business partners.
Gorrissen Federspiel closely follows the developments of sanctions against Russia and we can assist with the interpretation of and compliance with the applicable sanctions, as well as implementation of measures to ensure that sanctions are observed. If you have any questions, please contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletter of 19 December 2023, newsletter of 26 June 2023, newsletter of 27 February 2023, newsletter of 19 December 2022, newsletter of 7 October 2022, newsletter 8 June 2022, newsletter of 11 April 2022, Gorrissen Federspiel’s newsletter of 16 March 2022, Gorrissen Federspiel’s newsletter of 10 March 2022, Gorrissen Federspiel’s newsletter of 2 March 2022, Gorrissen Federspiel’s newsletter of 28 February 2022 and Gorrissen Federspiel’s newsletter of 24 February 2022.
[1] Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
[2] Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
[3] Council Implementing Regulation (EU) 2024/753 of 23 February 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
[4] Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.